HUD Waiver Question Answer Session April 6 2020

HUD Waiver Question & Answer Session April 6, 2020 3: 30 -4: 30 pm

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This webinar will begin soon For audio via telephone United States: : +1 (213) 929 -4232 Access Code: 181 -946 -877 Audio PIN: Shown after joining the webinar

HUD Waiver Question & Answer Session April 6, 2020 3: 30 -4: 30 pm

Webinar Housekeeping • Muted • Use *6 is you are on a PHONE to mute • Audio Troubleshooting • If you are having difficulty hearing us, please join the webinar via phone • Click on “Audio” and then click “Telephone”. Please follow dial in instructions • If you are on the phone, please do not put us on HOLD. • Questions • In the Questions/Chat Box

Questions/Chat • All lines are muted • Use the Question/Chat Box to submit questions, ideas, comments, resources, etc.

Goals Overview of the HUD Waivers & Applicability Ability to apply for a waiver Understanding of documentation for waiver

HUD’s Regulatory Waivers for Co. C, ESG & HOPWA

Overview of the HUD Waiver • Released on March 31, 2020 (announced April 1, 2020) • HUD’s Office of Community Planning and Development (CPD) • Formula programs and program-specific waivers for the following CPD programs: • Continuum of Care(Co. C); • Emergency Solutions Grant(ESG); and • Housing Opportunities for Persons with AIDS(HOPWA). • These waivers are intended to prevent the spread of COVID-19 and to facilitate assistance to eligible communities and households economically impacted by COVID-19. • Effects participants enrolled or housing entered into after March 31, 2020

HUD Waiver Breakdown by Program Type Co. C ESG HOPWA Con Plan 7 Waivers 4 Waivers 2 Waivers City of Chicago or direct Grantees City of Chicago Co. C Program Grantees

HUD Waiver Breakdown by Program Type: Consolidated Plan • Normal: 30 Days Citizen Participation Public Comment Period • Waiver: 5 days for Consolidated Plan Amendment Citizen Participation • Normal: Follow Citizenship Reasonable Notice and Participation Plan Opportunity to • Waiver: Requirement waived Comment

HUD Waiver Breakdown by Program Type: Emergency Solution Grants (ESG) HMIS Lead Activities Re-evaluations for Homelessness Prevention Assistance Housing Stability Case Management • Normal: Costs to HMIS Lead • Waiver: Costs to any recipient • Normal: Every 3 months • Waiver: Once every 6 months • Normal: Monthly • Waiver: As needed Restriction of Rental Assistance • Normal: At or below FMR to Units with Rent at or Below • Waiver: Can be above FMR

HUD Waiver Breakdown by Program Type: HOPWA Self-Certification of Income and Credible Information on HIV Status FMR Rent Standard Property Standards for TBRA Space and Security • Normal: Income & HIV Status documented • Waiver: Self-certify income and credible HIV. Obtain documentation within 3 months post-COVID crisis • Normal: Use FMR • Waiver: Does not need to use FMR but be reasonable for 1 year after HUD Memo • Normal: Must meet HQS • Waiver: Visually inspect and reinspect post-COVID crisis for 1 year after HUD Memo • Normal: Adequate space & security for self and belongings • Waiver: Can use optional space for households affected by COVID-19

HUD Waiver Breakdown by Program Type: Continuum of Care Fair Market Rent for Individual Units & Leasing Costs Disability Documentation for PSH Limit on Eligible Housing Search and Counseling Services Rapid Re-housing Monthly Case Management • Normal: Units paid with leasing (BLI) cannot exceed FMR • Waiver: FMR is waived for TH & PSH executed leases. Rent must be reasonable. For 6 months from HUD memo. • Normal: Must document disability within 45 days after intake worker observation • Waiver: Documentation is not required. 6 months from HUD memo. Selfcertification is sufficient. • Normal: Eligible costs include credit counseling, accessing a free personal credit report, and resolving personal credit issues • Waiver: Funds may be used for utility arrears and rent arrears(up to 6 months), when those arrears make it difficult to obtain housing. 1 year from HUD memo • Normal: Required monthly meeting with case manager • Waiver: Provide case management as needed; 2 months from date of HUD memo

HUD Waiver Breakdown by Program Type: Continuum of Care Housing Quality Standards (HQS) –Initial Physical Inspection of Unit HQS –Re-Inspection of Units One-Year Lease Requirement • Normal: Physically inspect any leasing or rental assistance unit for HQS • Waiver: Inspect using technology and reinspect physically post. COVID within 3 months. For 6 months from HUD memo date. • Normal: Annual inspection to ensure HQS • Waiver: Waived for 1 year from HUD memo date. • Normal: PSH units must have a one year lease term that is renewable and terminable for cause • Waiver: Initial lease term must be for at least one month. 6 months from HUD memo

Applying for the HUD Waiver

Steps for the HUD Waiver 1. Determine which waiver(s) you will use 2. Determine when you wish to start using the waiver(s) 3. Complete written notification to send to HUD 4. Send written notification to local HUD office 5. Implement waiver(s) & document written justification for their use 6. Obtain documentation when COVID crisis ends

Steps for the HUD Waiver 1. Determine which waiver(s) you will use 2. Determine when you wish to start using the waiver(s) • Review Availability of Waivers of CPD Grant Program and Consolidated Plan Requirements to Prevent the Spread of COVID-19 and Mitigate Economic Impacts Caused by COVID-19 • Review Guidance from All Chicago • You can start using the waiver 2 calendar days after you send your notification to HUD.

3. Complete written notification to send to HUD Appendix A lists the required elements for the notification to HUD • Requestor’s name, title, and contact information; • Declared-disaster area(s) where the waivers will be used; • Date on which the grantee anticipates first use of the waiver flexibility; and • A list of the waiver flexibilities the grantee will use: PROTIP: Use the HUD Waiver Notification Template created by All Chicago

3. Complete written notification to send to HUD Sample Written Notification to HUD

4. Send written notification to local HUD office All notifications for Chicago & Illinois are sent to the Chicago HUD CPD Office CPD_COVID-19 Waiver. CHI@HUD. gov

5. Implement waiver(s) & document written justification for their use 1. Start using the waiver(s) 2 calendar days after notifying HUD. 2. Update your program records to include written documentation of the specific conditions that justify your use of the waiver, consistent with the justifications and applicability provisions • Used for each time that each waiver is used • Consider Interim Recordkeeping Protocol Template as a guide.

6. Obtain documentation when COVID crisis ends 1. Public health department determines COVID crisis has ended. 2. Obtain documentation for waivers that require it Examples: HQS (Co. C, HOPWA), Income & HIV (HOPWA)

Questions & Answers

THANK YOU! • Contact us at Co. CPrograms@allchicago. org